Swedish Enterprise on The Battery Regulation

The Confederation of Swedish Enterprise supports the Commission’s work on sustainable products, in accordance with the Circular Economy Action Plan. The Swedish business community is already at the forefront of this work, and wishes to play a leading role in developing and contributing constructively to the European Commission’s work on the topic. The action plan contains a range of initiatives that the Confederation sees – if designed appropriately – can become valuable tools in enabling a transition into a circular economy. It is important that the work remains oriented towards securing the EU’s long-term competitiveness.

Electrification will be a vital tool in achieving the EU’s climate goals, and batteries will play an important role in the transition process. The Confederation of Swedish Enterprise is grateful for the opportunity to provide its inputs on the proposed battery regulation. Our comments address the proposal on a general level.

The Confederation finds both positive parts and some more troublesome suggestions in the Commission’s proposal. For instance, it is for positive that the Commission has selected a specific range of batteries to be covered by the product passport requirements, and that such requirements do not automatically apply to all types of batteries. It is also positive that the Commission suggests establishing a database where companies can retrieve secondary data for carbon footprint calculations. On the other hand, The Confederation finds it problematic that the legislation is extensive and that a large number of issues will be dealt with through so-called delegated acts. The proposal also contains a range of new initiatives that will entail increased reporting requirements for companies, and it is important that the demands for providing information always is proportionate to the benefit that such information ultimately provides. Within certain areas, the Confederation also sees a risk of double regulation.

Please read the Confederation of Swedish Enterprise Consultation response on The Battery Regulation below.